People v. Bautista
REITERATIONFacts
The Antecedents: An Information dated on or about November 2017 charged the accused with qualified trafficking in persons under Republic Act No. 9208, as amended by Republic Act No. 10364. The Information alleged that the accused recruited, obtained, hired, offered and transported a person who was a child at the time, by means including taking advantage of the victim's vulnerability and by receiving payments or benefits, for the purpose of prostitution and sexual exploitation. The alleged victim (identified in the record by initials) was a minor at the time of the events; the parties admitted the minor status during pre-trial. The prosecution presented eyewitness and testimonial evidence describing instances in which the accused allegedly recruited, transported, and offered the minor to customers and received monetary benefits. The accused denied the charges and claimed the allegations arose from a personal quarrel. Procedural History: The Regional Trial Court convicted the accused of qualified trafficking in persons and sentenced her to life imprisonment and a fine of PHP 2,000,000, and ordered payment of moral and exemplary damages. The Court of Appeals denied the accused's appeal and affirmed the RTC decision with modification imposing 6% per annum interest on damages from finality. The accused appealed to the Supreme Court. The Petition: The accused contended she was not guilty beyond reasonable doubt of the crime charged.
Issue(s)
Whether accused-appellant Ria Liza Bautista y Cariaga is guilty beyond reasonable doubt of qualified trafficking in persons under Republic Act No. 9208, as amended. Whether the alleged victim's consent is material or immaterial when the trafficked person is a child. Whether the penalties imposed by the trial court conform to the statutory prescriptions for qualified trafficking in persons. Whether the imposition of interest on damages at 6% per annum is proper.
Ruling
The Appeal is dismissed. The February 16, 2023 Decision of the Court of Appeals in CA-G.R. CR-HC No. 14678 is affirmed. Accused-appellant Ria Liza Bautista y Cariaga is found guilty beyond reasonable doubt of qualified trafficking in persons under Republic Act No. 9208, as amended, and sentenced to suffer life imprisonment and to pay a fine of PHP 2,000,000.00. She is ordered to pay the victim PHP 500,000.00 as moral damages and PHP 100,000.00 as exemplary damages, which shall bear interest at the rate of 6% per annum from the date of finality of the Decision until fully paid.
Ratio Decidendi
On Whether the accused is guilty beyond reasonable doubt of qualified trafficking in persons: The Court applied the statutory definition and elements of trafficking in persons under Section 3(a) and the acts under Section 4 of Republic Act No. 9208, as amended, and affirmed that the prosecution established the requisite acts, means, and purpose. It found that the accused performed acts enumerated in the statute by recruiting, offering and transporting the victim to customers and receiving financial benefits, and that these factual findings were supported by the positive testimony of the alleged victim; the trial court's assessment of credibility merited great respect. The Court emphasized that the victim was a child, satisfying the qualification under Section 6(a), and the prosecution proved the victim's minority by judicial admission and testimony. The Court rejected the accused's denial as an unsupported, self-serving defense that cannot prevail against positive identification and consistent testimony. Applying precedent, the Court held that the totality of evidence established guilt beyond reasonable doubt and affirmed the conviction. On Whether the alleged victim's consent is material when the trafficked person is a child: The Court held that the victim's consent is immaterial in cases involving a child, relying on Section 3(a), paragraph 2 of Republic Act No. 9208, as amended, and on People v. Dela Cruz. The Court explained that the statute expressly treats the recruitment, transportation, transfer, harboring or receipt of a child for exploitation as trafficking even if the means enumerated in Section 3(a) are not present, thereby rendering consent irrelevant. The Court reasoned that a minor cannot give valid consent to exploitative acts and that the law protects children by removing consent as a defense. It noted the prosecution established minority through judicial admission and the victim's testimony, obviating any need to prove coercion or deception to satisfy the means element in relation to a child. Therefore, even if the alleged victim showed aspects of willingness, such willingness does not negate criminal liability when the victim is a child. On Whether the penalties imposed conform to statutory prescriptions: The Court affirmed the penalty of life imprisonment and the fine of PHP 2,000,000.00 in accordance with Section 12(e) of Republic Act No. 10364, which prescribes life imprisonment and a fine ranging from PHP 2,000,000 to PHP 5,000,000 for qualified trafficking. The Court explained that the trial court imposed the minimum statutory fine and the prescribed penalty for qualified trafficking involving a child, which is proper given the gravity of the offense and the evidence. The Court further upheld the damages awarded by the trial court as proper remedies for the victim, given the proven exploitation. On Whether imposition of interest at 6% per annum on damages is proper: The Court affirmed the Court of Appeals' modification imposing 6% per annum interest on damages from finality until fully paid, citing prevailing jurisprudence (including People v. Dela Cruz) that supports the award of legal interest on money judgments for damages in criminal cases. The Court explained that the interest serves to fully compensate the victim and is routinely imposed in similar cases; therefore, the modification was appropriate.
Main Doctrine
When the trafficked person is a child, the elements of trafficking in persons under Republic Act No. 9208, as amended, are satisfied and the victim's consent is immaterial; qualified trafficking is established and punishable by life imprisonment and the statutory fine.